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OCC Sees De Novo Revival Amid Digital Trust Surge
The Office of the Comptroller of the Currency has received 14 de novo charter applications this year, nearly matching the previous four years combined. Comptroller Jonathan Gould said the resurgence signals renewed confidence and healthy competition, despite criticism from industry groups over crypto related trust applications. Gould argued that national trust banks have long engaged in nonfiduciary custody services and that restricting them would disrupt trillions in existing activity.
Dec 11, 2025
Tags: Industry News Market Risk
OCC Sees De Novo Revival Amid Digital Trust Surge
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• OCC receives 14 de novo charter applications in 2025
• Comptroller Jonathan Gould says activity marks a return to normal
• Surge driven partly by national trust charter applications from digital asset firms
• Industry groups argue nonfiduciary custody breaks with precedent
• Gould says national trusts have offered such services for decades
• Nearly two trillion dollars in nonfiduciary custodial assets held by trust banks
• Gould says digital custody mirrors long standing electronic practices
• FDIC leaders also call for renewed support for new bank formation

The Office of the Comptroller of the Currency is experiencing a marked resurgence in de novo charter activity, with 14 applications filed so far in 2025. 

Comptroller Jonathan Gould said Monday that the uptick represents a return to normal after years in which applicants were discouraged by regulatory uncertainty.

Speaking at the Blockchain Association’s policy summit, Gould noted that this year’s filings nearly match the total number of applications the agency received across the previous four years. 

He said the trend reflects rising confidence in the national banking charter and renewed appetite for innovation.

The sharp increase in national trust charter applications, he added, is a sign of healthy competition in a sector that has long supported digital and fiduciary services.

The OCC oversees about 60 national trust banks that provide fiduciary services such as asset management but do not take deposits or issue traditional loans. 

Many recent applicants come from the cryptocurrency and digital asset industries, a development that has drawn criticism from bank trade groups.

Industry associations argue that allowing national trust banks to participate in nonfiduciary custody activities departs from historical precedent. 

They warn that expanding these permissions could blur the line between full service national banks and trust institutions, potentially weakening long standing regulatory distinctions.

Gould rejected that interpretation, insisting the OCC has permitted national trust banks to perform nonfiduciary custody activities for decades.

He said blocking digital asset oriented trust firms would undermine the adaptability of the federal banking system and threaten more than a trillion dollars in traditional custody activity already conducted by existing national trust banks.

According to Gould, most national trust banks engage in custody and safekeeping. In the third quarter alone, they held nearly two trillion dollars in nonfiduciary custodial or safekeeping assets under administration, representing roughly a quarter of their total assets under administration.

He also argued that while some digital or fintech charter applicants may appear unfamiliar to traditional banking audiences, their proposed activities are consistent with the long standing nature of trust services. 

He pointed out that banks have electronically managed rights to company shares for decades and that digital assets should not be treated differently simply because the technology has evolved.

His remarks align with calls from other regulators to encourage new bank formation. Travis Hill, acting chair of the Federal Deposit Insurance Corporation, said in April that new bank creation had fallen dramatically in recent years and urged policymakers to support more entrants into the system.

Gould positioned the OCC’s recent experience as evidence that the sector is thawing. 

The rise in de novo applications, he said, reflects growing recognition that national charters, including trust charters, can support emerging technologies without abandoning established regulatory safeguards.

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